Zabetti A. Pappas - Page 61




                                       - 61 -                                         
          expenses of $223 in 1990 with respect to the apartment on W. 58th           
          Street.                                                                     
               Petitioner continued to rent the apartment on E. 65th Street           
          for business purposes during 1990.  She asserts, and respondent             
          concedes, that she is entitled to a deduction for rent of $13,983           
          and utility expenses of $790 in 1990 with respect to the                    
          apartment on E. 65th Street.                                                
               In 1990, petitioner continued to live in the apartment on E.           
          77th Street.  As was the case for 1989, however, we do not accept           
          her uncorroborated testimony regarding exclusive business use of            
          the furniture or any portion of the space.  She has thus failed             
          to demonstrate that she is entitled to any business-related                 
          deductions for 1990 rental costs of this property.  Petitioner              
          has also failed to prove to our satisfaction that $857 of                   
          furniture she claims to have purchased in 1990 was used in her              
          trade or business and thus could be deducted as a business                  
          expense or in the form of depreciation deductions.  See secs.               
          162(a), 167(a).                                                             
               Respondent has allowed petitioner $100 for messenger                   
          expenses in 1990 and an additional $114 in shipping and mailing             
          expenses.  Petitioner has satisfied us that she is entitled to              
          claim an additional $12.60 in mailing expenses, but she has not             
          provided substantiation for an additional claimed $114.75 for               
          such expenses.                                                              






Page:  Previous  51  52  53  54  55  56  57  58  59  60  61  62  63  64  65  66  67  68  69  70  Next

Last modified: May 25, 2011